The South Carolina Supreme Court affirmed Kenneth Henry Eastwood's murder conviction Tuesday, ruling that while the trial court committed error in excluding polygraph evidence, the mistake was harmless and did not affect the jury's verdict in the strangulation death of Cara Hodges.
In *State v. Eastwood* (S.C. 2025), the high court addressed the narrow issue of whether Eastwood should have been allowed to present evidence that police told him he failed a polygraph test shortly before he confessed to the killing. Eastwood sought to introduce this evidence to support his claim that his confession was false.
The case began when Hodges disappeared and her body was discovered four days later in a wooded area beside a dirt road. An autopsy revealed she had been strangled to death. Investigators learned that Eastwood was the last person seen with the victim, prompting them to contact him for questioning.
Eastwood voluntarily accompanied investigators to the Orangeburg County Sheriff's Office, where he received Miranda warnings and submitted to an interview. During the questioning, Eastwood admitted he had been drinking with Hodges on the day and night of her disappearance. He told officers that she had stayed at his house that night, and when he woke up the next day, she was gone.
After approximately one hour of questioning, Eastwood agreed to take a polygraph examination. Following the test, officers informed Eastwood that he did not pass and that they believed he was lying to them. Eastwood subsequently consented to providing a DNA swab and allowed investigators to search his home and car. Officers also photographed several scratches on Eastwood's chest, which he claimed were cat scratches.
The timeline of events became crucial to Eastwood's defense strategy. His attorneys argued that the polygraph results and the officers' statements about his failure created psychological pressure that led to a false confession. They contended that evidence of the failed polygraph test was essential to establish the context in which the confession was obtained and to support their argument that it was unreliable.
At trial, Eastwood's defense team sought to present testimony about the polygraph test and the officers' statements to him about failing it. The prosecution objected, and the trial court ruled the evidence inadmissible. This ruling became the sole issue on appeal.
Writing for the Supreme Court, Justice Hill acknowledged that the trial court erred in excluding the polygraph evidence. The court explained that while polygraph results themselves are generally inadmissible in South Carolina courts due to reliability concerns, evidence about polygraph examinations can sometimes be admitted for limited purposes, such as explaining the context of a confession or supporting claims about police interrogation tactics.
The court distinguished between the polygraph results themselves and evidence about the examination process and its psychological impact on a defendant. In this case, Eastwood was not seeking to introduce the actual test results to prove his truthfulness, but rather to provide context for his subsequent confession and to support his defense theory that the confession was involuntary or unreliable.
However, the Supreme Court applied the harmless error doctrine, concluding that despite the trial court's mistake, the error did not affect the outcome of the case. The court examined the strength of the remaining evidence against Eastwood and determined that the jury's verdict would have been the same even if the polygraph evidence had been admitted.
The harmless error analysis considered several factors, including the physical evidence linking Eastwood to the crime, witness testimony about his relationship with the victim, and other circumstantial evidence presented at trial. The court found that this evidence was sufficiently strong to support the conviction independent of the confession.
The ruling establishes important precedent for the admissibility of polygraph-related evidence in South Carolina criminal cases. While the court reaffirmed that polygraph results themselves remain inadmissible, it recognized that evidence about the examination process may be relevant in certain circumstances, particularly when defendants claim their confessions were coerced or unreliable.
The decision also demonstrates the application of harmless error doctrine in cases involving evidentiary mistakes. Even when courts commit procedural errors, convictions can be upheld if the remaining evidence is sufficient to support the verdict.
Eastwood was represented by Adam Sinclair Ruffin of Ruffin Law Firm in Columbia. The state was represented by Attorney General Alan McCrory Wilson, Senior Assistant Deputy Attorney General Melody Jane Brown, Assistant Attorney General Kaylee Christene Kemp, and Solicitor David Michael Pascoe Jr.
The case was heard by the Supreme Court on Sept. 23, 2025, and the opinion was filed Nov. 19, 2025. The conviction stems from proceedings in Orangeburg County Circuit Court under Judge Maite Murphy.
The ruling clarifies the boundaries of polygraph evidence admissibility while upholding the conviction in a case involving serious violent crime. Defense attorneys may find the decision useful in future cases where polygraph examinations precede confessions, though they will need to demonstrate that such evidence is essential to their defense strategy and that excluding it would affect the trial's outcome.